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about September 27, 1982. This is after the 1982 tax return
filing date (Aug. 21, 1982), and matches the date of the refund
of $81,054.77. See supra note 4 and associated text. We are
satisfied, and we have found, that the $54,372.61 transfer was a
transfer of part of the tax refund claimed on the 1981 tax
return.
We hold for respondent on this issue.
As a result, we hold that Nancy fails to qualify for
innocent spouse treatment under section 6013(e).
To reflect the foregoing and the parties' settlement of
other issues,
Decision will be entered in
accordance with the parties'
stipulations, as described supra in
note 2.
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